Pub. 7 2018 Issue 3

The CommunityBanker 16 Expiring Individual Taxpayer Identification Numbers (ITINs) By Patti Joyner Blenden The IRS has made changes to the Individual Taxpayer Identification Number (ITIN) program as a result of the Protecting Americans from Tax Hikes (PATH) Act. E very financial institution must be knowledgeable regarding tax - payer identification numbers used to uniquely identify account holders. The Bank Secrecy Act’s (BSA) Customer Identification Program (CIP) rule implements Section 326 of the USA PA- TRIOT Act and requires each bank to implement a written CIP appropriate for its size and type of business including certain minimum requirements. The CIP must be incorporated into the bank’s BSA/AML compliance program subject to approval by the bank’s board of directors. The CIP is intended to enable the bank to form a reasonable belief if it knows the true identity of each customer. The CIP must include account opening proce- dures specifying identifying information to be obtained from each customer and reasonable risk-based procedures for verify- ing the identity of each customer. At a minimum, obtain and verify the following identifying information from each customer before opening the account: